Privacy Policy__

PURPOSE

• Visitor Bay Inc. (“Visitor Bay”)recognizes the importance of privacy and the risk of the unauthorized use or disclosure of personal information that comes into the possession or control of Visitor Bay from the use by its customers’ visitors of the Visitor Bay application.
• Visitor Bay further recognizes the necessity to design and implement measures for the security of personal information that comes into the possession or control of Visitor Bayfrom the use by its customers’ visitors.
• The purpose of this Privacy Policy is to describe the types of personal information collected from customers using the Visitor Bay application, how such information is used and the measures taken by Visitor Bay to ensure its privacy and security.

DEFINITIONS

• In this Privacy Policy, unless otherwise stated, the following terms shall have the meaning prescribed for each:
• • (a) "Personal Information" means all information about an identifiable individual provided or otherwise collected by the interactive function of the Visitor Bay application. Personal information includes all information about an identifiable person and includes for purposes of this Privacy Policy the person's full name, email address, phone number, company name and company address.
  • (b) "Application" means the application designed and developed by Visitor Bay which includes an interactive function for the visitor management system licensed by Visitor Bay’s customers.

APPLICABILITY

• 5. This Privacy Policy applies to Visitor Bay, its customers and its customers’ visitors accessing the Application. It describes the technology and procedures of Visitor Bay to ensure the privacy and security of any Personal Information which it may receive.

POLICY

• Visitor Bay is committed to ensuring the privacy and security of Personal Information and to meeting its obligations under all applicable Canadian privacy legislation.
• Visitor Bay is committed to collecting, using and disclosing Personal Information provided by customers through the Application only for reasonable and bona fide business-related purposes.
• Visitor Bay is committed to taking all reasonable steps to ensure the continuing privacy and security of all Personal Information provided by customers through the Application.
• Visitor Bay has established the position of Privacy Officer, responsible for the development and implementation of all necessary rules and procedures for the collection, use, disclosure and retention of Personal Information, including Personal Information provided by customers through the Application. The Privacy Officer will ensure compliance with this Privacy Policy and all applicable privacy legislation.

PRIVACY STANDARDS

• Personal Information of visitors disclosed through their use of the Application will be collected, used and disclosed by Visitor Bayonly for reasonable, business-related purposes, and in accordance with the following privacy principles:
• • (a) Consent.
  • • Express consent is required for the collection, use and disclosure ofPersonal Information. A customer and a customers’ visitor’s consent to the use of their Personal Information disclosed through their use of Application is implied for the purposes of the Applicationand other reasonably expected business-related purposes.
    • Visitor Bay may use and disclose Personal Information provided by customers through the Application, without consent, for compliance with any applicable law, regulation, or the order of any court or other lawfully constituted authority.
  • (b) Limiting Collection.The collection of Personal Information from customers and visitors through the Application will be restricted to that required by Visitor Bayto undertake the business-related purposes for which it was provided and for Visitor Bayto meet its legal obligations.
  • (c) Limiting the Use, Disclosure, and Retention of Personal Information. Personal Information collected from customers through the Application will be used, disclosed and retained only for reasonably expected business-related purposes, or for compliance with any applicable law, regulation, or order of any court or other lawfully constituted authority.
  • (d) Security of Personal Information. Visitor Bay will take all commercially reasonable steps to protect Personal Information from unauthorized access, use or disclosure. Reasonable steps include physical, electronic and procedural measures appropriate to the level of sensitivity of the Personal Information.
  • (e) Response to Inquiries and Complaints. The Privacy Officer will investigate and respond to all customer complaints in regard to the treatment of their Personal Information at the earliest opportunity. If the complaint is found to be justified, the Privacy Officer will so inform the customer and ensure that appropriate corrective measures are taken.

CONTACT

Questions concerning this policy should be brought to the attention of the Company Privacy Officer.